SecProbe.io

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 June 6, 2025

Wai Yiu Yau
Chairman of the Board and Chief Executive Officer
Globavend Holdings Limited
Office 1401, Level 14, 197 St Georges Tce
Perth, WA 6000
Australia

 Re: Globavend Holdings Limited
 Registration Statement on Form F-1
 Filed May 22, 2025
 File No. 333-287533
Dear Wai Yiu Yau:

 We have conducted a limited review of your registration statement and
have the
following comment(s).

 Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a comment applies to your
facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

 After reviewing any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments.

Registration Statement on Form F-1 filed May 23, 2025
Cover Page

1. Please revise your cover page caption to clearly disclose all the
securities being
 registered. In this regard, we note that your fee table indicates that
the Series A
 Warrants, Series B Warrants, and Pre-Funded Warrants are being
registered in
 addition to the Ordinary Units, Pre-Funded Units, and Ordinary Shares
underlying the
 Ordinary Units, Pre-Funded Warrants, Series A Warrants, and Series B
Warrants.
 June 6, 2025
Page 2
Risk Factors
This offering may result in an immediate trading halt or delisting of our
Ordinary Shares,
page 14

2. We note your response to prior comment 1. To contextualize your
disclosure
 regarding the risk of an immediate trading halt or delisting, please
revise to clarify
 whether to your knowledge Nasdaq has found a public interest concern
related to
 other offerings that include warrants with zero exercise or similar
features. In
 addition, revise your prospectus summary disclosure to provide
 appropriate discussion.
Exhibits

3. We note that the legal opinion filed as Exhibit 5.1 states that Conyers
acted as special
 Cayman Islands legal counsel to you in connection with this registration
statement for
 the offering of (i) up to 16,176,471 ordinary units ( Ordinary Units
) whereby each
 Ordinary Unit consists of one ordinary share, par value US$0.001 per
share of the
 Company (the Ordinary Share ), one Series A warrant to purchase one
Ordinary
 Share (each a Series A Warrant , and, collectively, the Series A
Warrants ), and
 one Series B warrant to purchase one Ordinary Share (each a Series B
Warrant , and,
 collectively, the Series B Warrants ); and (ii) up to 16,176,471
pre-funded units
 ( Pre-Funded Units and collectively with the Ordinary Units, the
Units ), each
 consisting of one pre-funded warrant to purchase one Ordinary Share
(each a Pre-
 Funded Warrant, and, collectively, the Pre-Funded Warrants )
(the Pre-Funded
 Warrants, Series A Warrants and Series B Warrants collectively, the
Warrants ), one
 Series A Warrant and one Series B Warrant in lieu of the Ordinary Units
where
 purchase of the Ordinary Units in the Offering would result in the
relevant purchaser,
 together with its affiliates, beneficially owning more than 4.99% (or,
at the election of
 the purchaser, 9.99%) of the outstanding Ordinary Shares immediately
following the
 consummation of the Offering, if they so choose. However, we note that
the Series A
 Warrants, Series B Warrants, Pre-Funded Warrants, and Ordinary Shares
underlying
 the Ordinary Units, Series A Warrants, Series B Warrants, and Pre-Funded
Warrants
 are also being registered. Please have counsel revise the legal opinion
to reflect all the
 securities being registered in this registration statement or advise.
4. Please also have counsel revise the legal opinion to opine that the
Ordinary Shares
 underlying the Units will be validly issued, fully paid and
non-assessable when issued
 upon exercise of the Units. Refer to Section II.B.1.a and h. of Staff
Legal Bulletin No.
 19.
5. Please file an opinion of counsel that opines that the Units and
Warrants constitute
 binding obligations of the company. For guidance, please refer to
Section II.B.1.f and
 h. of Staff Legal Bulletin No. 19.

 We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.
 June 6, 2025
Page 3

 Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

 Please contact Irene Barberena-Meissner at 202-551-6548 or Daniel Morris
at 202-
551-3314 with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Energy &
Transportation
cc: Aaron M. Schleicher, Esq.
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